On behalf of the Safe Food Coalition and the Worker Health and Safety Coalition, congratulations on your new position as OIRA Administrator. In anticipation that the U.S. Department of Agriculture will send OMB its proposed regulation to modify its poultry slaughter inspection program (Docket No. RIN 0583–AD32), the undersigned organizations write to express serious concerns about the proposed rule and its impact on public health and the safety and health of poultry workers. We urge you to notify USDA that these concerns cannot be addressed without restarting the rulemaking process.

USDA’s proposal does not require plants to test for Salmonella or Campylobacter, the two pathogens most frequently associated with raw poultry. The Centers for Disease Control and Prevention’s most recent report card on foodborne illness showed a 14 percent increase in Campylobacter illness rates and no change in rates of Salmonella illnesses. Further, a study by the University of Florida ranked poultry contaminated with Campylobacter (#1) and Salmonella (#4) in the top five pathogen/food combinations that cause the greatest disease burden to the public. And a recent report by the Center for Science in the Public Interest found that more outbreaks were linked to chicken over the past 12 years than to any other meat or poultry product.

USDA’s proposal also allows each plant to decide the level of bruises, feathers, bile or ingesta appropriate for birds going down the processing line, rather than setting uniform standards across the industry. Further, the rule removes inspectors from the slaughter line and turns over inspection activities, previously conducted by federal inspectors, to plant employees who are not required to be trained in their new duties. USDA also proposes to allow plants to increase their line speeds up to 175 chicken carcasses per minute, meaning that the lone remaining inspector on the slaughter line will have 1/3 of a second to examine each chicken carcass for problems.

Despite these concerns, USDA has not held public meetings to discuss such substantial changes to its poultry inspection program.

USDA’s proposed rule will also have a serious detrimental impact on the industry’s workers. Fast line speed is already a major cause of high injury rates among poultry processing workers. A recent report based on more than 300 worker interviews by the Southern Poverty Law Center and the Alabama Appleseed Center for Law and Justice found that 72 percent of poultry workers had suffered a significant job-related injury or illness and that the workers, many whom are immigrants, are often silenced from reporting injuries or making complaints about working conditions by threats of deportation and firing.

Further, a recent Health Hazard Evaluation published by the National Institute for Occupational Health and Safety (NIOSH) found an alarming 42 percent of workers at one poultry plant in South Carolina had indications of carpal tunnel syndrome even before the scheduled line speed increase took effect at that plant. Workers of color, immigrants, and women are overrepresented in the poultry-processing industry and will bear a disproportionate share of the rule’s likely negative health impacts. The worker health and safety community has implored USDA to withdraw the poultry rule until the agency, at a minimum, develops a comprehensive plan to mitigate the serious concerns about line speed and preventable injuries.

USDA’s poultry inspection system does need to be modernized, but this proposal raises serious food safety and worker safety concerns. We urge you to notify USDA that these concerns must be addressed through a new rulemaking process.

Sincerely,

American Federation of Government Employees

Center for Effective Government

Center for Food Safety

Center for Foodborne Illness Research & Prevention

Center for Science in the Public Interest

Centro de los Derechos del Migrante, Inc.

Consumer Federation of America

Coalition for Sensible Safeguards

Consumers Union

El Comite de Apoyo a los Trabajadores Agricolas

Food & Water Watch

Government Accountability Project

Migrant Clinicians Network

National Consumers League

National Council of La Raza (NCLR)

National Council for Occupational Safety and Health

Nebraska Appleseed Center for Law in the Public Interest

New York Committee for Occupational Safety and Health

Public Justice Center

Southern Poverty Law Center

South Florida Interfaith Worker Justice

STOP Foodborne Illness

United Food and Commercial Workers International Union

United Support and Memorial for Workplace Fatalities

U.S. Public Interest Research Group

Voces de la Frontera Workers Center

Workers’ Center of Central New York

Worksafe, Inc.

(Affiliations for identification purposes)

James Albers, MPH CIH, Cincinnati, OH

Dan Berman, PhD
Author of “Death On the Job”

Kathy Black
Health & Safety Director
AFSCME DC47

Liz Borkowski
Research Associate
Department of Environmental & Occupational Health
George Washington University School of Public Health & Health Services

Linda Forst, MD, MPH
Professor and Division Director
Environmental and Occupational Health Sciences
University of Illinois Chicago School of Public Health

Barbara A. Silverstein, MSN, PhD, MPH, CPE Research Director
Safety and Health Assessment and Research for Prevention (SHARP) Program
Washington State Department of Labor and Industries
Olympia ,WA

Nancy Simcox

Craig Slatin, Sc.D., MPH
Professor, Department of Community Health and Sustainability
University of Massachusetts Lowell
Editor, New Solutions, A Journal of Environmental and Occupational Health Policy

Rena Steinzor
Professor, University of Maryland Carey School of Law
Baltimore, MD